• Skip to primary navigation
  • Skip to main content

USC Department of Contracts and Grant

University of Southern California
  • Home
    • Pre-Award Overview
    • Post-Award Overview
    • Subawards Overview
    • Explore DCG Resources
    • Feedback
    • Service Agreements
  • Pre-Award
    • Complete Proposal
    • Roles and Responsibilities
    • Find Funding
    • Review Funding
    • Compliance Requirements
    • Route in Cayuse SP
    • DCG Review
    • Sponsor Review
    • Post Submission
  • Post-Award
    • Roles and Responsibilities
    • Award Setup
    • Award Guidance
    • Outgoing Subawards
    • Progress Reports and Deliverables at USC
    • Award Closeout
  • Subawards
    • Defining Subawards
    • Outgoing Subawards at Proposal Stage
    • Setting Up and Modifying Outgoing Subawards
    • Monitoring of Subawards
    • DCG Contacts for Questions on Outgoing Subawards
    • Forms
  • DCG Training
    • Training for Principal Investigators
    • Training for Research Administrators
    • Training for Cayuse SP
    • MicroLearning Videos
  • Resources
    • General Guidance
    • Roles and Responsibilities Made Easy
    • Roles and Responsibilities in Research Administration
    • USC Policies and Training Programs
    • Common Forms and Templates
    • Sponsor Resources for Research Administrators
    • Notifications Regarding Federal Directives
    • USC Research Administration Navigator Use
    • USC Research Administration Navigator FAQ
    • Write Better Prompts. Get Better Answers.
  • Directory
You are here: Home / Announcements / NIH Reminder on the Definition of Foreign Components

NIH Reminder on the Definition of Foreign Components

May 29, 2026

The National Institutes of Health (NIH) has recently released Notice NOT-OD-26-084 to remind the extramural research community of NIH’s longstanding definition of a “foreign component” and related disclosure expectations.

Importantly, NIH clarified that the agency has not changed or expanded the definition of a foreign component, even as oversight of foreign collaborations continues to increase.

Why This Matters

NIH continues to closely monitor foreign collaborations and undisclosed foreign activities associated with federally funded research. Failure to appropriately disclose foreign components may result in additional NIH review, compliance actions, or restrictions on funding activities.

Principal Investigators, departments, and research administrators should carefully review foreign collaborations, publication co-authorship, and project activities to ensure alignment with NIH policy and award terms.

NIH Definition of a “Foreign Component”

According to the NIH Grants Policy Statement, a foreign component is:

“The performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.”

Examples of activities that may constitute a foreign component include:

  • Involvement of human subjects or animals at a foreign site

  • Significant foreign travel for data collection, surveying, sampling, or similar activities

  • Use of foreign facilities, instrumentation, or resources

  • Receipt of financial support or resources from a foreign entity

  • Collaborations with investigators at foreign sites anticipated to result in co-authorship

NIH clarified that foreign travel strictly for consultation purposes generally does not constitute a foreign component.

Important Clarification Regarding Foreign Co-Authorship

NIH noted that most instances of foreign co-authorship represent a foreign component, though some limited exceptions may apply where contributions are considered minor or indirect.

Examples provided by NIH include:

  • Provision of a single reagent that results in co-authorship

  • Indirect association through a shared domestic collaborator

NIH expects recipients to report foreign co-authorship to the funding Institute or Center as soon as they become aware of it, so NIH can determine whether additional action is necessary.

Review NOFO Restrictions Carefully

Recipients are reminded to closely review the applicable Notice of Funding Opportunity (NOFO) to determine whether foreign components are allowable under a specific program.

Certain NIH programs prohibit foreign components entirely. NIH specifically highlighted the Institutional Development Award (IDeA) program as an example where foreign components are not permitted.

For awards that prohibit foreign components, publications and research activities generally should not include foreign collaborators or co-authors associated with the NIH-funded work.

Publication Acknowledgement and Grant Attribution Reminders

NIH also reiterated federal funding acknowledgement requirements under the Stevens Amendment.

Recipients must ensure that publications and other materials accurately:

  • Acknowledge NIH support appropriately

  • Identify the percentage and dollar amount of federally funded project costs, where applicable

  • Clearly distinguish NIH-supported work from unrelated activities

NIH emphasized that investigators should avoid citing NIH awards that did not actually support the published work, as inaccurate attribution may result in compliance concerns.

Investigators should also ensure that publication affiliations accurately reflect where NIH-funded work was performed.

Additional Information

Full NIH Notice: NOT-OD-26-084
Release Date: May 27, 2026

Questions regarding NIH foreign component disclosures may be directed to the appropriate NIH Institute or Center, or to your DCG Officer for institutional guidance and support.

Filed Under: Announcements

USC Office of Research and Innovation
Department of Contracts and Grants
3720 S. Flower St.
Los Angeles, CA 90089-0701

University of Southern California - Content managed by DCG
  • Privacy Notice - Notice of Non-Discrimination